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You must consider an injury or illness to be work-related if an event or exposure in the work
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environment discernibly caused or contributed to the resulting condition, or if an event or
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exposure occurring in the work environment is a discernable cause of a significant aggravation to
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a preexisting injury or illness. The work event or exposure need only be one of the causes of, or
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contributors to, the resulting injury or illness; it need not be the sole or predominant cause or
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contributor. Work-relatedness is presumed for injuries and illnesses resulting from events or
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exposures occurring in the work environment, even if the injury or illness does not have a clear
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connection to a specific work activity or is not occupational in nature.
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Injuries and illnesses that occur at work may not have a clear connection to a specific work
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activity, condition, or substance that is peculiar to the employment environment. For example,
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an employee may trip for no apparent reason while walking across a level factory floor; be
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sexually assaulted by a co-worker; or be injured accidentally as a result of an act of violence
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perpetrated by one co-worker against a third party. In these and similar cases, the employee’s
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job-related tasks or exposures did not create or contribute to the risk that such an injury would
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occur. Nevertheless, these cases are work-related. The causal connection is established by the
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fact that the injury would not have occurred but for the conditions and obligations of
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employment that placed the employee in the position in which he or she was injured or made ill.
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An injury or illness is not reportable if the injury or illness involves signs or symptoms that
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manifest themselves at work but result solely from a non-work-related event or exposure that
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occurs outside the work environment. See reporting exceptions listed at § 225.15.
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If it is not obvious whether the precipitating event or exposure that caused or contributed to an
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injury or illness occurred in the work environment or elsewhere, the employer must evaluate the
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employee’s work duties and environment to decide whether one or more events or exposures in
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the work environment caused or contributed to the resulting condition, or significantly
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aggravated a preexisting condition. As long as the event or exposure occurred at work and is a
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discernable cause of the injury or illness or is a discernable cause of a significant aggravation to
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a preexisting injury or illness, the injury or illness is work-related. If an injury is within the
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presumption of work-relatedness, the employer can rebut work-relatedness only by showing that
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the case falls within an exception listed in § 225.15. This means that the employer must make a
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determination as to whether it is more likely than not that work events or exposures were a
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discernable cause of the injury or illness, or a discernable cause of a significant aggravation to a
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preexisting condition. The evaluation might include consultation with an ergonomics expert as
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well as a PLHCP. A review of the job description, alone, is not sufficient without reviewing all
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of the employee’s collateral duties. If the employer decides the case is not work-related, and
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FRA subsequently issues a citation for failure to report, the Government would have the burden
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of proving that the injury or illness was work-related.
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FRA Guide for Preparing Accident/Incident Reports
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53
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F 6180.55a
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6.6.1 Interpretations on Work-Relatedness
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Scenario 1:
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An employer asks if an injury or illness sustained by an on-duty employee while he or she is
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engaged in an activity, such as walking or bending, is considered work-related. The employer
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notes that a case is presumed to be work-related if an event or exposure in the work environment
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discernibly caused or contributed to the injury or illness. The work event or exposure need only
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be one of the causes or contributions to the injury or illness; it need not be the sole or
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predominant cause.
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Response 1:
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The question employers must answer is whether there is an identifiable event or exposure that
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occurred in the work environment and resulted in the injury or illness. Thus, if an employee trips
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while walking across a level shop floor, the resulting injury is considered work-related because
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the precipitating event—the tripping accident—occurred in the workplace. The case is workrelated even if the employer cannot determine why the employee tripped, or whether any
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particular workplace hazard caused the accident to occur.
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The activity engaged in by the employee at the time of the injury—walking—is an “event” that
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would trigger application of the presumption. Other examples of events include sneezing,
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climbing, tripping, and bending down. In the absence of evidence to overcome the presumption,
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the injury is work-related. Thus, in the absence of evidence to overcome the presumption, an
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ankle injury caused by a trip that occurred while the employee was walking down a level
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seamless hallway at work is work-related, regardless of whether the accident is attributable to a
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defect in the hall. By the same reasoning, if the activity of walking down a hallway caused the
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employee’s knee to buckle or to sprain the ankle, the injury is work-related. If an injury or
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illness did not result from an identifiable event or exposure in the work environment, but only
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manifested itself during work, the injury is not work-related. For example, if the employee had a
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non-occupational event or exposure, and there is no evidence of a work-related event or exposure
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that caused or contributed to the injury or illness, the injury should not be reported.
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There is also the issue of whether the determination of work-relatedness is affected by an
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employee’s preexisting condition. For reporting purposes, a preexisting condition is an injury or
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illness resulting solely from a non-work-related event or exposure. If an employee’s preexisting
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condition is worsened as a result of an event or exposure at work, the case is work-related if the
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work event or exposure “significantly aggravated” the preexisting condition (i.e., discernibly
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caused the case to meet any of the general criteria).
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If an employee with a previous work-related injury to a body part suffers a subsequent workrelated injury of the same type to the same body part, the subsequent injury is reportable
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(assuming the general reporting criteria are met) if it is a “new case” as described in this chapter.
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FRA Guide for Preparing Accident/Incident Reports
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54
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F 6180.55a
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If the subsequent injury is not a “new case,” then the railroad is required to update the previously
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submitted injury or illness report if necessary.
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Scenario 2:
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An employee reported to work at 7:00 a.m. At 12:15 p.m., the employee reported that his toes
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on his left foot started swelling and his foot started hurting. The employee wanted to go to a
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doctor for evaluation.
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On the first report of injury that the employee completed before he went to the doctor,
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the employee indicated that the cause of the illness was “unknown.”
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When answering the doctor’s question: “How did the injury occur?,” the employee answered
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that the only thing he could think of was that his feet were wet all the previous day due to work
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in the morning at a cooling tower. The cooling tower water is treated to remove bacteria and
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then used in process operations in the plant.
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The doctor described the illness/injury as foot edema/cellulitis. The doctor also diagnosed the
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injury as an occupational disease, prescribed an antibiotic, and the employee missed 1 day of
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work. The company sent the employee to a second doctor who said to continue using the
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antibiotic. Neither doctor could state conclusively that the foot edema/cellulitis was or was not
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due to the employee’s feet being wet due to work at the cooling tower. Neither doctor is a
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specialist in skin disorders.
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During an incident review at the site, the employee again said he did not know if his feet being
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wet all day the previous day caused the injury/illness. The employee also stated that he had not
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worn the personal protective equipment—rubber boots—prescribed for this task.
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The company determined that this injury/illness was not work-related (did not occur in the
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course of or as a result of employment), since neither physician nor the employee could state
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